Foreign Account Tax Compliance Act

The Foreign Account Tax Compliance Act is a United States federal statute enacted in 2010 as part of the Hiring Incentives to Restore Employment Act (HIRE Act). FATCA aims to improve compliance of U.S. taxpayers... more +

The Foreign Account Tax Compliance Act is a United States federal statute enacted in 2010 as part of the Hiring Incentives to Restore Employment Act (HIRE Act). FATCA aims to improve compliance of U.S. taxpayers by capturing tax revenue related to foreign assets and off-shore accounts. less -

As 2016 comes to a close, U.S. FATCA is almost fully phased-in, U.K. FATCA is being phased-out and the Common Reporting Standard (“CRS”) is nearing the first anniversary of its effective date. What began as a concept in 2010...more

Global tax evasion remains a major problem for governments around the world. At a time when virtually all of the governments from the world’s major economies seek additional revenue, the attractiveness to taxpayers of...more

Thinking about giving up your US citizenship pending the results of the Presidential election in November 2016? Concerned because you have been an “Expat” for a long time and have not filed US Tax returns? Just realized that...more

Pre-immigration and Non-U.S. Resident Planning -
It does not matter whether foreign individuals are investing in U.S. property and hoping to become residents in the U.S., or are planning to invest in U.S property...more

Foreign individuals who intend to permanently reside in the U.S., or do not intend to reside in the U.S. but intend to own U.S. property, need considerable legal and tax planning. The definition of “U.S. property” for...more

The Tax Court, in American Metallurgical Coal Co., TC Memo 2016-139, recently held that financing of a sale of partnership interests by a foreign seller to a U.S. buyer was not debt, but equity. The court found that the...more

Leakage of profits to offshore locations and tax evasion through aggressive planning has always been a hot topic in Ukraine. However, it must be said that, with the exception of the introduction of transfer pricing rules in...more

Part I of this series focused on the unforeseen nightmare and problem of unfiled tax returns for undocumented immigrants. The consequences of “kicking the can down the road”, will have significant legal and financial...more

Did you know that, under Internal Revenue Code, Section 6620, if a taxpayer does not timely file a U.S. tax return, the IRS is authorized to prepare and file a U.S. tax return for that taxpayer based on the knowledge that it...more

During the June 24, 2016 Tax Controversy Conference held at New York University, officials from both the Department of Justice (DOJ) and the Internal Revenue Service (IRS) emphasized their focus on analyzing the avalanche of...more

Recently, The Harvard Law School Forum on Corporate Governance and Finance published a note titled "The Legal Consequence of Brexit, authored by Simon Witty. We have restated the transactional tax commentary here. We have...more

As noted in the Foley Adviser dated April 14, 2016, there are several upcoming FATCA-related deadlines, two of which are right around the corner:
..June 30, 2016: Foreign Financial Institution Due Diligence for...more

On 9 May 2016, Singapore passed the Income Tax (Amendment No. 2) Act 2016 (Amendment Act). This is a first step towards the implementation of the Common Reporting Standards (CRS) developed by the Organisation for Economic...more

Many U.S. expatriate taxpayers are receiving “FATCA” letters from offshore banks around the world. The banks are sending the letters in anticipation of their I.R.S. FATCA reports of U.S. taxpayer offshore financial...more

IRS has asked involved U.S. taxpayers to come forward before IRS reads and dissects the “Panama Papers”. IRS will “plan how to use the huge trove of leaked documents to catch criminals — and urged Americans to come clean now...more

Something that most of us don’t realize is that Internal Revenue Service has stated that the taxpayer is responsible to learn IRS requirements within the historic U.S. framework of a voluntary reporting system.
The IRS...more

U.S. Taxpayers who directly or indirectly controlled foreign financial accounts in 2015 are reminded that the deadline to file a Report of Foreign Financial Account (FBAR) FinCEN Form 114 is June 30. Taxpayers with unfiled...more

In the wake of the "Panama Papers" – the unprecedented leak of 11.5 million files from a Panamanian law firm that revealed thousands of names and addresses linked to offshore companies – the White House has announced several...more

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